Supreme Court Acquits Accused in Murder Case Citing Lack of Evidence: Raghunatha vs. State of Karnataka (21 March 2024)

Introduction

Date of the Judgment: 21 March 2024
Citation: 2024 INSC 238
Judges: B.R. Gavai, J. and Sandeep Mehta, J.

Can a conviction be sustained solely on circumstantial evidence if the chain of circumstances is not fully established? The Supreme Court of India recently addressed this critical question in a criminal appeal, ultimately acquitting the accused due to insufficient evidence. The case revolved around the murder of a man, with the prosecution relying on circumstantial evidence such as the “last seen” theory, motive, and recovery of the weapon. The bench, comprising Justices B.R. Gavai and Sandeep Mehta, delivered the judgment.

Case Background

On 7th July 2014, Sri R. Lokanathan (PW-1) filed a complaint with the Kaamasamudram police, leading to the registration of Crime No. 44/2014 under Section 302 of the Indian Penal Code, 1860 (IPC). The complaint stated that the complainant and his father, Ramu (the deceased), ran a fertilizer shop and were also involved in agriculture and money lending. The prosecution alleged that Raghunatha (Accused No. 1) had a business dispute with the complainant, leading to enmity. Raghunatha, along with Manjunatha (Accused No. 2), allegedly conspired to murder Ramu. On the morning of 7th July 2014, Ramu left his house on a TVS Moped to recover a loan. The accused allegedly ambushed him on the road, with Accused No. 2 fatally assaulting him with a chopper. Babu (PW-6), the complainant’s uncle, discovered the unattended moped and informed the complainant, who then found Ramu with severe injuries. Ramu was taken to KGF Hospital, where he was declared dead. The accused were arrested on 23rd July 2014, and subsequently charged under Sections 120-B and 302 read with Section 34 of the IPC.

Timeline:

Course of Proceedings

The trial court convicted the appellants under Sections 120-B and 302 read with 34 of the IPC, sentencing them to life imprisonment and imposing a fine of Rs. 7,500 each, with Rs. 25,000 to be paid as compensation to the complainant. The High Court, in its judgment, partly allowed the appeal, modifying the conviction to Section 304 Part-I of the IPC. The High Court sentenced the appellants to 10 years of imprisonment and imposed a fine of Rs. 75,000 each, with Rs. 1,40,000 to be paid to Sarla (PW-7), the deceased’s wife. The Supreme Court heard the appeal against this judgment.

Legal Framework

The case primarily involves the interpretation and application of the following sections of the Indian Penal Code, 1860:

• Section 120-B, IPC: This section deals with the punishment for criminal conspiracy. It states that a person who is a party to a criminal conspiracy to commit an offense punishable with death, imprisonment for life, or rigorous imprisonment for a term of two years or more, shall be punished in the same manner as if he had abetted such offense.
• Section 302, IPC: This section defines the punishment for murder. It states that whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.
• Section 34, IPC: This section deals with acts done by several persons in furtherance of common intention. It states that when a criminal act is done by several persons in furtherance of the common intention of all, each of such persons is liable for that act in the same manner as if it were done by him alone.
• Section 304 Part-I, IPC: This section deals with culpable homicide not amounting to murder. It states that whoever commits culpable homicide not amounting to murder shall be punished with imprisonment for life, or imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine, if the act by which the death is caused is done with the intention of causing death, or of causing such bodily injury as is likely to cause death.

Arguments

Appellants’ Arguments:

• The appellants argued that the trial court and the High Court erred in convicting them.
• They contended that the case was based on circumstantial evidence, and the prosecution failed to prove any of the incriminating circumstances.
• The appellants submitted that the prosecution failed to establish a complete chain of circumstances that would lead to no other conclusion than their guilt.

Respondent-State’s Arguments:

• The State argued that both the lower courts had concurrently held that the prosecution had proven a chain of circumstances pointing to the guilt of the accused.
• The State submitted that no interference was warranted in the present appeal.

Submissions by Appellants:

• The prosecution failed to prove the “last seen” theory, as the witnesses did not see the deceased in the company of the appellants.
• The motive was not established with cogent and convincing evidence, as the alleged financial loss and enmity were not adequately proven.
• The recovery of the chopper from an open place did not conclusively link the appellants to the crime.

Submissions by Respondent-State:

• The prosecution had successfully established the “last seen” theory through the testimonies of Sarla (PW-7) and Shivaraj (PW-8).
• The motive for the crime was adequately proven by the business dispute between the complainant and Accused No. 1.
• The recovery of the chopper used in the crime was a crucial piece of evidence that linked the accused to the murder.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame specific issues in a separate section. However, the main issue that the Court addressed was:

• Whether the prosecution had successfully established a chain of circumstantial evidence to prove the guilt of the accused beyond a reasonable doubt.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues:

Authorities

The Supreme Court relied on the following authorities:

Cases:

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

The Court relied on Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116]* to reiterate the five golden principles for cases based on circumstantial evidence. It also used Hanumant v. State of Madhya Pradesh [(1952) 2 SCC 71]*, Tufail (Alias) Simmi v. State of Uttar Pradesh [(1969) 3 SCC 198]*, and Ramgopal v. State of Maharashtra [(1972) 4 SCC 625]* to emphasize the need for a complete chain of evidence. The Court also cited Shivaji Sahabrao Bobade v. State of Maharashtra [(1973) 2 SCC 793]* to highlight the distinction between “may be” and “must be” guilty, stressing that the accused must be proven guilty, not merely suspected of guilt.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the lack of conclusive evidence presented by the prosecution. The Court emphasized that the circumstances from which guilt is inferred must be fully established, and the chain of evidence must be so complete as to leave no reasonable doubt about the accused’s guilt. The Court found that the “last seen” theory was not proven, the motive was not established with convincing evidence, and the recovery of the weapon from an open place did not conclusively link the accused to the crime. The court also stressed that suspicion, however strong, cannot replace proof beyond a reasonable doubt. The Court underscored that the accused ‘must be’ and not merely ‘may be’ proved guilty before a court can convict the accused.

Sentiment Analysis of Reasons Given by the Supreme Court:

Fact:Law Ratio

Logical Reasoning

Issue: Whether the prosecution had successfully established a chain of circumstantial evidence to prove the guilt of the accused beyond a reasonable doubt.

Key Takeaways

• Burden of Proof: The prosecution must establish a complete chain of circumstantial evidence to prove guilt beyond a reasonable doubt.
• Last Seen Theory: The “last seen” theory requires concrete evidence of the deceased being in the company of the accused, not merely being seen nearby.
• Motive: The motive for a crime must be established with cogent and convincing evidence, not mere assumptions.
• Recovery of Evidence: Recovery of a weapon from an open place accessible to all does not conclusively link the accused to the crime.
• Suspicion vs. Proof: Suspicion, however strong, cannot replace proof beyond a reasonable doubt.
• Accused’s Rights: An accused is presumed innocent until proven guilty beyond a reasonable doubt.

Directions

The Supreme Court directed that:

• The impugned judgment of the High Court and the judgment of the trial court are quashed and set aside.
• The appellants are acquitted of all charges and are to be released forthwith if not required in any other case.

Specific Amendments Analysis

There is no specific amendment analysis in this judgment.

Development of Law

The ratio decidendi of this case is that in cases based on circumstantial evidence, the prosecution must establish a complete chain of circumstances that leads to no other conclusion than the guilt of the accused. The Court reiterated the principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116]* and other cases, emphasizing that the circumstances must be fully established, consistent with the guilt of the accused, and exclude every other hypothesis. This case reinforces the need for a high standard of proof in criminal cases, particularly those based on circumstantial evidence, and highlights that suspicion, however strong, cannot replace proof beyond a reasonable doubt. There is no change in the previous position of law, rather it reinforces the settled principles of law.

Conclusion

In the case of Raghunatha and Another vs. The State of Karnataka, the Supreme Court acquitted the appellants, reversing the High Court’s decision. The Court found that the prosecution failed to establish a complete chain of circumstantial evidence, emphasizing that the “last seen” theory was not proven, the motive was not established with convincing evidence, and the recovery of the weapon from an open place did not conclusively link the accused to the crime. The judgment underscores the importance of a high standard of proof in criminal cases, particularly those based on circumstantial evidence, and reinforces the principle that an accused is presumed innocent until proven guilty beyond a reasonable doubt.